Tag Archives: OVDP

#Americansabroad connect through @IsaacBrockSoc – It’s the #FATCA of the matter

Great and interesting post about U.S. citizenship abroad. Some familiar faces. The post includes:

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Some compliance thoughts from @Mopsicktaxlaw – Responding to #FATCA

Interesting FATCA and tax compliance post from Mr. Mopsick which includes:

For both Americans abroad and recent immigrants: Millions of people are agonizing over the question, “Should I just blow it off or do I really need to take some action?” The answer is easy: Whether you take action or not is all based on your personal tolerance level for risk and uncertainty. It is your decision to make. Many people are totally comfortable with the idea that they will never get caught violating the tax laws by not reporting foreign income and accounts or for some reason don’t care if they do get caught. This is because it is one thing for the IRS to compute a tax due and owing from a delinquent taxpayer, but the IRS is years away from routine collection in the ordinary course of delinquent taxes from Americans overseas, provided there are no periodic or regular payments like Social Security payments or pension payments leaving the US for accounts abroad.

Leaving one with the question for Americans abroad:

Is it more dangerous to be IN tax compliance or NOT in tax compliance?

Time will tell. If Mr. Mopsick is correct in his analysis, this suggests those NOT in tax compliance have time to respond to their situation and NOT react!




The #FATCA IGA aka #OVDP for countries


The above tweet references a comment at the Isaac Brock Society:

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#OVDP for financial advisors – coming soon to a bank near you!

The threat of FATCA enforcement has impacted every jurisdiction in the world and the global financial industry is quaking with fear. The US Justice Department has taken the position that the entire non-US financial industry is potentially part of a continuing criminal conspiracy with some US individuals and multi-national companies to evade US income tax.  The Justice Department has unilaterally forged ahead to obtain indictments and convictions over prominent foreign banks, bankers, and some of their US customers.  The United States justification for claiming the moral high ground is that it is merely seeking to have all US taxpayers pay tax as required under US law.

FATCA – Predictions of implementation failure proving true

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It’s Official: New OVDP program designed for Swiss Banks

The title of the article by Lynnley Browning is:

“Swiss  agree on penalties for banks that aided tax cheats”

A review of the article suggests that the U.S. government is attempting to impose on Swiss Banks a program that is like the “OVDI-OVDP” program.

The article begins with:

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Streamlined compliance may now be an option for those who wish to file amended returns!

Assuming the correctness of this, it is very big. It signals that the focus of the IRS may be moving away from penalties and toward getting people back into the system! Note the discussion of the role of Taxpayer Advocate.

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